U.S. Department of Health and Human Services, Family Planning Services, ALN 93.217; Prevention and Health Promotion Administration--Refugee and Entrant Assistance State/Replacement Designee Administered Programs, ALN 93.566 Criteria Under the Uniform Guidance, time and effort records must be supported by a system of internal controls which provides reasonable assurance that charges are accurate, allowable and allocable and incorporated in the official records. Condition and Context Time charges to federal awards are based upon estimates established by CCI through the grant budgeting process. There is no evidence that salaries charged to the federal programs were subsequently reviewed by program managers for propriety and adjusted as deemed necessary. Cause Significant turnover within the organization within the Finance and Grants Departments. Effect Federal awards may be overcharged or undercharged. Questioned Cost Unknown. Repeat Finding No. Recommendation We recommend that management adhere to its policy requiring the Finance and Grants Manager to meet after each pay period to review the time and labor charges to federal awards, noting any changes that need to be made. We also recommend that this meeting, review and any amendments made be documented and evidenced by signatures or initials of the employees involved in the process and the date the meeting occurred. Views of Responsible Officials and Planned Corrective Action See corrective action plan.
Condition There is no formal documentation or evidence to support that competitive price analysis for vendors selected by CCI several years ago or that suspension and debarment verifications were performed for vendors, as required by the general procurement standards of the Uniform Guidance. Context We selected two samples which were deemed sole sourced by management and noted no written documentation for this conclusion or evidence of suspension or debarment verification being performed was maintained in the file. Based on our discussions with management, we understand that the arrangements with these vendors were established several years ago. Criteria Under Uniform Guidance Section 200.318, General Procurement Standards, a non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity?s documented procurement procedures must conform to the procurement standards identified in Sections 200.317 through 200.327. These sections include policies and procedures related to competition, informal and formal procurement methods and noncompetitive procurement also known as sole source. Under Uniform Guidance Section 200.214, Suspension and Debarment and 2 CFR part 180, non-federal entities are required to verify that vendors are not suspended or debarred from participating in federal funds. Cause CCI?s procurement policy was not updated to include the provisions of the general procurement standards required under the Uniform Guidance. Effect Charges relating to vendor services that were charged to the federal award may not be in accordance with the Uniform Guidance. Questioned Costs None. Repeat Finding Yes. Recommendation We recommend that CCI update its existing procurement policy governing contracts with vendors that will be reimbursed by federal grants to incorporate all of the provisions included in the general procurement standards of the Uniform Guidance Section 200.318 and the debarment and suspension regulations of Uniform Guidance Section 200.214. We also recommend that a review of all vendor contract files be performed to ensure that the documentation as required under the Uniform Guidance is maintained in the files. Views of Responsible Officials and Planned Corrective Action See corrective action plan.
U.S. Department of Health and Human Services, Family Planning Services, ALN 93.217; Prevention and Health Promotion Administration--Refugee and Entrant Assistance State/Replacement Designee Administered Programs, ALN 93.566 Criteria Under the Uniform Guidance, time and effort records must be supported by a system of internal controls which provides reasonable assurance that charges are accurate, allowable and allocable and incorporated in the official records. Condition and Context Time charges to federal awards are based upon estimates established by CCI through the grant budgeting process. There is no evidence that salaries charged to the federal programs were subsequently reviewed by program managers for propriety and adjusted as deemed necessary. Cause Significant turnover within the organization within the Finance and Grants Departments. Effect Federal awards may be overcharged or undercharged. Questioned Cost Unknown. Repeat Finding No. Recommendation We recommend that management adhere to its policy requiring the Finance and Grants Manager to meet after each pay period to review the time and labor charges to federal awards, noting any changes that need to be made. We also recommend that this meeting, review and any amendments made be documented and evidenced by signatures or initials of the employees involved in the process and the date the meeting occurred. Views of Responsible Officials and Planned Corrective Action See corrective action plan.
U.S. Department of Health and Human Services (HHS), Family Planning Services, ALN 93.217 Criteria The HHS grant agreement requires that federal financial reports be submitted within 30 days after the end of each quarter. Also, the final report is required to be filed within 90 days of the end of the reporting period. Additionally, in accordance with the Uniform Guidance, the audit package and the Data Collection Form must be submitted within 30 days after receipt of the auditor?s report or nine months after the end of the fiscal year, whichever comes first. Condition The final federal financial report (Form 425) for the period January 1, 2022 through March 31, 2022 and the quarterly report for period June 1, 2021 through September 30, 2021 were not submitted to HHS by the required due dates. In addition, the Data Collection Form for the year ended June 30, 2022, was not submitted to Federal Audit Clearinghouse by the due date. Context The final form 425 was due to HHS June 30, 2022, but was submitted on September 15, 2022. The quarterly report was due to HHS October 30, 2021, but was submitted on November 1, 2021. In terms of the Data Collection Form for the year ended June 30, 2022, this report has not been submitted yet. This report was due on March 31, 2023. Cause Staff turnover in the finance department and insufficient tracking system to ensure deadlines are met. Effect Management is not in compliance with the requirement of the grant agreement and OMB Uniform Guidance. Questioned Costs None Repeat Finding No. Recommendation We recommend that management implement procedures to ensure that all federal reports are filed by the required due date. Views of Responsible Officials and Planned Corrective Action See corrective action plan.
U.S. Department of Health and Human Services, Family Planning Services, ALN 93.217; Prevention and Health Promotion Administration--Refugee and Entrant Assistance State/Replacement Designee Administered Programs, ALN 93.566 Criteria Under the Uniform Guidance, time and effort records must be supported by a system of internal controls which provides reasonable assurance that charges are accurate, allowable and allocable and incorporated in the official records. Condition and Context Time charges to federal awards are based upon estimates established by CCI through the grant budgeting process. There is no evidence that salaries charged to the federal programs were subsequently reviewed by program managers for propriety and adjusted as deemed necessary. Cause Significant turnover within the organization within the Finance and Grants Departments. Effect Federal awards may be overcharged or undercharged. Questioned Cost Unknown. Repeat Finding No. Recommendation We recommend that management adhere to its policy requiring the Finance and Grants Manager to meet after each pay period to review the time and labor charges to federal awards, noting any changes that need to be made. We also recommend that this meeting, review and any amendments made be documented and evidenced by signatures or initials of the employees involved in the process and the date the meeting occurred. Views of Responsible Officials and Planned Corrective Action See corrective action plan.
Condition There is no formal documentation or evidence to support that competitive price analysis for vendors selected by CCI several years ago or that suspension and debarment verifications were performed for vendors, as required by the general procurement standards of the Uniform Guidance. Context We selected two samples which were deemed sole sourced by management and noted no written documentation for this conclusion or evidence of suspension or debarment verification being performed was maintained in the file. Based on our discussions with management, we understand that the arrangements with these vendors were established several years ago. Criteria Under Uniform Guidance Section 200.318, General Procurement Standards, a non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity?s documented procurement procedures must conform to the procurement standards identified in Sections 200.317 through 200.327. These sections include policies and procedures related to competition, informal and formal procurement methods and noncompetitive procurement also known as sole source. Under Uniform Guidance Section 200.214, Suspension and Debarment and 2 CFR part 180, non-federal entities are required to verify that vendors are not suspended or debarred from participating in federal funds. Cause CCI?s procurement policy was not updated to include the provisions of the general procurement standards required under the Uniform Guidance. Effect Charges relating to vendor services that were charged to the federal award may not be in accordance with the Uniform Guidance. Questioned Costs None. Repeat Finding Yes. Recommendation We recommend that CCI update its existing procurement policy governing contracts with vendors that will be reimbursed by federal grants to incorporate all of the provisions included in the general procurement standards of the Uniform Guidance Section 200.318 and the debarment and suspension regulations of Uniform Guidance Section 200.214. We also recommend that a review of all vendor contract files be performed to ensure that the documentation as required under the Uniform Guidance is maintained in the files. Views of Responsible Officials and Planned Corrective Action See corrective action plan.
U.S. Department of Health and Human Services, Family Planning Services, ALN 93.217; Prevention and Health Promotion Administration--Refugee and Entrant Assistance State/Replacement Designee Administered Programs, ALN 93.566 Criteria Under the Uniform Guidance, time and effort records must be supported by a system of internal controls which provides reasonable assurance that charges are accurate, allowable and allocable and incorporated in the official records. Condition and Context Time charges to federal awards are based upon estimates established by CCI through the grant budgeting process. There is no evidence that salaries charged to the federal programs were subsequently reviewed by program managers for propriety and adjusted as deemed necessary. Cause Significant turnover within the organization within the Finance and Grants Departments. Effect Federal awards may be overcharged or undercharged. Questioned Cost Unknown. Repeat Finding No. Recommendation We recommend that management adhere to its policy requiring the Finance and Grants Manager to meet after each pay period to review the time and labor charges to federal awards, noting any changes that need to be made. We also recommend that this meeting, review and any amendments made be documented and evidenced by signatures or initials of the employees involved in the process and the date the meeting occurred. Views of Responsible Officials and Planned Corrective Action See corrective action plan.
U.S. Department of Health and Human Services (HHS), Family Planning Services, ALN 93.217 Criteria The HHS grant agreement requires that federal financial reports be submitted within 30 days after the end of each quarter. Also, the final report is required to be filed within 90 days of the end of the reporting period. Additionally, in accordance with the Uniform Guidance, the audit package and the Data Collection Form must be submitted within 30 days after receipt of the auditor?s report or nine months after the end of the fiscal year, whichever comes first. Condition The final federal financial report (Form 425) for the period January 1, 2022 through March 31, 2022 and the quarterly report for period June 1, 2021 through September 30, 2021 were not submitted to HHS by the required due dates. In addition, the Data Collection Form for the year ended June 30, 2022, was not submitted to Federal Audit Clearinghouse by the due date. Context The final form 425 was due to HHS June 30, 2022, but was submitted on September 15, 2022. The quarterly report was due to HHS October 30, 2021, but was submitted on November 1, 2021. In terms of the Data Collection Form for the year ended June 30, 2022, this report has not been submitted yet. This report was due on March 31, 2023. Cause Staff turnover in the finance department and insufficient tracking system to ensure deadlines are met. Effect Management is not in compliance with the requirement of the grant agreement and OMB Uniform Guidance. Questioned Costs None Repeat Finding No. Recommendation We recommend that management implement procedures to ensure that all federal reports are filed by the required due date. Views of Responsible Officials and Planned Corrective Action See corrective action plan.